First Bank v. Eastern Livestock Co.

837 F. Supp. 792, 23 U.C.C. Rep. Serv. 2d (West) 933, 1993 U.S. Dist. LEXIS 16341, 1993 WL 477641
CourtDistrict Court, S.D. Mississippi
DecidedJuly 27, 1993
DocketCiv. A. J92-0469(L)(C)
StatusPublished
Cited by14 cases

This text of 837 F. Supp. 792 (First Bank v. Eastern Livestock Co.) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
First Bank v. Eastern Livestock Co., 837 F. Supp. 792, 23 U.C.C. Rep. Serv. 2d (West) 933, 1993 U.S. Dist. LEXIS 16341, 1993 WL 477641 (S.D. Miss. 1993).

Opinion

MEMORANDUM OPINION AND ORDER

TOM S. LEE, District Judge.

This cause is before the court on the motion of plaintiff First Bank and the cross motion of defendant Eastern Livestock Company (Eastern) for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure. Each party has responded to the motion of the other and the court has considered the memoranda of authorities, together with attachments, submitted by the parties. The court concludes, based on its review of applicable authorities and its evaluation of the parties’ evidence, that both parties’ motions must be denied.

FACTS

Eastern is a company which is engaged in the day-to-day purchase of farm products (cattle). Beginning in January 1989, Eastern engaged in cattle purchase and sales transactions with one Harry Wells, an individual in the business of buying and selling cattle. Through a series of cattle purchase confirmation contracts between Wells and Eastern, Wells took delivery of cattle from Eastern over a period of months and, after “fattening” the cattle, resold the cattle to Eastern by a date agreed upon by those parties in their contracts and at a prearranged price per pound. On May 23, 1989, Eastern tendered to Wells a check in the amount of $253,647.92, representing payment for the fatted cattle that Wells resold to it under the contracts.

First Bank, contending that it held a prior perfected security interest as to the cattle involved in these transactions, brought this action for conversion against Eastern seeking to recover the full amount paid by Eastern to Wells. On its present motion for summary judgment, First Bank alleges that it did all that was necessary under the law to perfect its security interest in the cattle which Eastern purchased from Wells and that Eastern, despite having both actual and constructive notice of the Bank’s lien, paid the entire *794 purchase price for the cattle to Wells alone, in violation of the Bank’s security interest. Finally, First Bank avers that Wells, though indebted to it for a sum in excess of the $253,647.92 paid to him by Eastern, has never accounted to or paid First Bank any of the money which Eastern paid to him. Thus, First Bank argues that it is entitled to summary judgment against Eastern on its complaint for conversion. Eastern denies that First Bank is entitled to judgment in its favor, and claims, to the contrary, that judgment should be entered for Eastern since First Bank did not have a perfected security interest in the subject cattle.

One who violates a valid security interest of a financial institution by not accounting to that financial institution for its security interest is subject to liability for conversion of the institution’s funds. See Oxford Production Credit Ass’n v. Dye, 368 So.2d 241 (Miss.1979); United States v. Harrell’s Stockyards, Inc., 652 F.Supp. 452 (S.D.Miss.1987). The issue presented by this case is whether Eastern purchased cattle from Wells subject to a prior perfected security interest by First Bank. The answer to the question depends, ultimately, on whether First Bank had a valid security interest in the cattle that was ■ the subject of the Eastern/Wells transaction and if so, whether it complied with the requirements of state and federal law pertaining to the giving of notice of its alleged security interest to prospective buyers of the cattle, including Eastern.

THE FOOD SECURITY ACT AND MISSISSIPPI’S CENTRAL FILING SYSTEM

In 1985, Congress, finding that certain State laws allowed a secured lender to “enforce liens against a purchaser of farm products even if the purchaser [did] not know that the sale of the products violate[d] the lender’s security interest in the products, lack[ed] any practical method for discovering the existence of the security interest, and ha[d] no reasonable means to ensure that the seller use[d] the sales proceeds to repay the lender,” 7 U.S.C. § 1631(a), passed the 1985 Farm Bill, popularly known as the Food Security Act (the FSA), “to remove [the] burden on and obstruction to interstate commerce in farm products” caused by such State laws, 7 U.S.C. § 1631(b). In order to make information more readily available to purchasers of farm products, the FSA provides for the establishment by each state of a “central filing system” in order that lenders may file “effective financing statements ... on a statewide basis.” 7 U.S.C. § 1631(c)(2). This is accomplished by the lender’s filing of the prescribed financing statement with the office of the State’s Secretary of State. Under the FSA, the State’s Secretary of State is required to maintain a master list of all financing statements filed by lenders, and to make that list available on a regular basis to buyers of farm products who register to receive information concerning debtors. 7 U.S.C. § 1631(c)(2)(D). Buyers who do not register pursuant to subsection (e)(2)(D) may nevertheless receive information concerning a debtor by requesting such information of the Secretary of State in accordance with the procedures established by the FSA.

On December 24,1986, following Congress’ enactment of the FSA, Mississippi’s Secretary of State prescribed regulations for the implementation of a central filing system in conformity with the requirements set forth in the FSA for the centralized filing of security interest documents covering farm products. See Miss.Code Ann. § 75-9-319 (directing Secretary of State to issue regulations). 1 The FSA provides that “in the case of a farm product produced in a State that has established a central filing system,” a buyer of farm products will take such products subject to a security interest created by the seller if

(A) the buyer has failed to register with the Secretary of State of such State prior to the purchase of farm products; and
*795 (B) the secured party has filed an effective financing statement or notice that covers the farm products being sold....

7 U.S.C. § 1631(e)(2). 2 Unless these conditions are satisfied, then,

notwithstanding any other provision of Federal, State, or local law, a buyer who in the ordinary course of business buys a farm product from a seller engaged in farming operations shall take free of a security interest created by the seller, even though the security interest is perfected; and the buyer knows of the existence of such interest.

7 U.S.C.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
837 F. Supp. 792, 23 U.C.C. Rep. Serv. 2d (West) 933, 1993 U.S. Dist. LEXIS 16341, 1993 WL 477641, Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-bank-v-eastern-livestock-co-mssd-1993.